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Voluntary Measures: An Inadequate Solution to a Pressing Problem

July 23, 2015

Today, the Environmental Protection Agency (EPA) announced its new “Natural Gas STAR Methane Challenge Program,” a collection of voluntary measures aimed to reduce methane pollution from existing sources. In January, as part of its announced plan to reduce oil and gas industry methane emissions 40-45% by 2025, the Administration committed to issuing regulations for new and modified sources. However, it declined to commit to a regulatory approach for existing sources of pollution – equipment in operation before the new rules are proposed – opting instead to rely, in part,[1] on today’s “Natural Gas STAR Methane Challenge Program” for methane emission reductions from those sources. Moreover, in its announcement, the Administration stated that “[a]chieving significant methane reductions from these voluntary industry programs and state actions could reduce the need for future regulations,” a view we believe is seriously misguided.

It is no secret: methane emissions from the Oil and Natural Gas sector are an enormous problem. Methane is a potent greenhouse gas, with more than 80 times the warming power of carbon dioxide in the first 20 years after it is released into the atmosphere. Not only does methane pollution and its associated climate change impacts threaten public health, it is a waste of a valuable energy resource. Enough natural gas is wasted each year through methane leaks to fuel nearly 6 million homes. Reducing methane pollution from the oil and natural gas industry is a critical tool to slow the rate of short-term climate change, and reductions from existing sources are essential. According to an analysis performed by ICF International, nearly 90 percent of the sector’s methane emissions in 2018 will be emitted by existing sources that were operating back in 2011. For the vast majority of these older existing sources, nothing requires oil and gas companies to limit their emissions.

Legally speaking, neither the “Natural Gas STAR Methane Challenge Program” nor other voluntary efforts such as OneFuture or the Downstream Initiative – both of which were also referenced in the January announcement – will “reduce the need” for future regulations. When EPA regulates methane from new and modified sources within the sector under section 111(b) of the Clean Air Act, something the White House pledged to do in the January announcement and that we are anxiously awaiting, EPA will also have a statutory duty under section 111(d) of the Act to issue guidelines for states to reduce methane emissions from existing sources. The standards established under section 111(d) must be legally enforceable, something that, by definition, voluntary programs are not.

Critically, the number of sources addressed – and thus the magnitude of reductions achieved – under a voluntary program approach will almost certainly pale in contrast to what can be achieved under nationally applicable and legally enforceable section 111(d) standards. We know from experience that because participation in the “Natural Gas STAR Methane Challenge Program” is a choice, many oil and gas companies will choose not to participate.  The oil and gas industry repeatedly argues that it can be trusted to on its own to take the steps needed to reduce methane emissions, and that regulation is not needed, but the low participation rate proves otherwise.

To see real world evidence of this, one can consider the low participation rate in EPA’s longstanding voluntary program, Natural Gas STAR. Despite its having been in existence, in one form or another, for over 20 years, only just over twenty oil and gas producers are signed up as “Partners” with Natural GasSTAR. This is out of over six thousand oil and gas producing companies in the US (see section 2.6 of this document).

Further evidence comes from data that industry is required to report to EPA. It is well documented that replacing high-emitting pneumatic controllers (devices which automatically open and shut valves at oil and gas sites) with cleaner devices pays for itself in just a few years, because the cleaner devices keep more gas in the system that the oil and gas companies can sell. Replacing these devices is simple and very feasible (some companies have done it across their operations; Colorado required them to be replaced statewide) and vastly reduces air pollution. Yet, over 30,000 of these outdated devices are still in use!

For these reasons, and as we have noted here before, voluntary programs for reducing methane emissions are a poor surrogate for actual regulations. The fact that 90 percent of the methane emissions from the sector will come from older sources, after Natural Gas STAR has been in place for many years, provides strong evidence that voluntary approaches are utterly inadequate. Since they have not solved the problem in the past, we have little reason today to believe that yet another voluntary program will solve it this time.

Surely voluntary programs have their place in promoting innovative solutions to environmental issues. But there are reasonable-cost technologies and practices that are available right now to greatly reduce industrial methane pollution! We do not need to wait to fix this problem. Allowing large portions of the industry to fall further behind in implementing these solutions on existing sources is, literally, passing this enormous problem off for another day.

EPA’s “Natural Gas STAR Methane Challenge Program” does not remedy the need for strong, legally enforceable regulation on existing sources of methane pollution, and won’t adequately reduce emissions from this industry. In other words, contrary to the Administration’s claim, the “Natural Gas STAR Methane Challenge Program” does not “reduce the need” for robust and timely section 111(d) regulations.


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